Joint Comments to the Board Requesting an Extension on the Stress Test NPR Comment Deadline

Dear Ms. Misback:

The Bank Policy Institute, the American Bankers Association, the Financial Services Forum, the Securities Industry and Financial Markets Association, and the International Swaps and Derivatives Association, Inc. (the "Associations") respectfully request that the Federal Reserve Board (the "Board") extend by 30 days the current January 22, 2026 deadline for public comments on its Notice of Proposed Rulemaking on Enhanced Transparency and Public Accountability of the Supervisory Stress Test Models and Scenarios and Modifications to the Capital Planning and Stress Capital Buffer Requirement Rule, Enhanced Prudential Standards Rule, and Regulation LL (including the proposed changes to the FR Y-14 reports included in the release), issued on October 24, 2025 (the "Enhanced Transparency NPR"). The Associations are not requesting an extension of the December 1, 2025 comment period deadline with respect to the Board’s Notice of Proposed Rulemaking regarding the Request for Comment on Scenarios for the Board’s 2026 Supervisory Stress Test, which the Board also issued on October 24, 2025.

The Board's stated goal of the Enhanced Transparency NPR is to solicit public input regarding the models used to conduct the Board's supervisory stress test, the changes to those models to be implemented in the 2026 stress test, and proposed changes to enhance the transparency and public accountability of the Board’s stress testing framework. In connection with the Enhanced Transparency NPR, the Board is requesting public comment on comprehensive model documentation, which contains almost 1,500 pages of technical detail. The Associations are engaged in a careful review and analysis of the Enhanced Transparency NPR and the related documentation, and will prepare a comment letter that we expect will provide the Board with helpful feedback and analysis to improve its supervisory stress testing process.

The Associations are concerned that the existing comment deadline will not provide sufficient time to perform the level of analysis that the NPR warrants, particularly given the voluminous documentation accompanying the Enhanced Transparency NPR. In 2023, for example, the Board determined that it was appropriate to extend the comment period for its interagency proposal to implement Basel III Endgame by almost 50 days. In comparison to the Basel III Endgame proposal, the Enhanced Transparency NPR and the related documentation posted to the Board’s website are lengthier, more detailed and more technical. In addition, the Associations also cannot prepare meaningful comments on several aspects of the Enhanced Transparency NPR—in particular regarding the Board’s proposed new pre-provision net revenue model—until the Board discloses additional information, including coefficients, aggregated historical data, and/or discount factors.

For these reasons, the Associations respectfully request that the Board extend the deadline for comments on the NPR for at least an additional 30 days, with a new deadline for public comments of no earlier than February 21, 2026. Our goal is to develop a carefully considered and well-informed comment letter that will be constructive for the Board in accomplishing its goal of enhancing the transparency and public accountability of the stress test process, which this additional time would facilitate.

Thank you for your consideration of this request.

Sincerely,

/s/ Sarah Flowers
Sarah Flowers
Senior Vice President, Head of Capital Advocacy
Bank Policy Institute

/s/ Hu Benton
 Hu Benton
Senior Vice President and Policy Counsel
American Bankers Association

/s/ Sean Campbell
Sean Campbell
Chief Economist, Head of Policy Research
Financial Services Forum

/s/ Guowei Zhang
Guowei Zhang
Managing Director, Head of Capital Policy
Securities Industry and Financial Markets Association

/s/ Lisa Galletta
Lisa Galletta
Head of U.S. Prudential Risk
International Swaps and Derivatives Association, Inc.